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The impact of war in Ukraine and Russian sanctions: a UK tax adviser’s guide

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The war in Ukraine has led to legislative changes that are potentially broad in their scope and application and the consequences for breach are severe. New regulations require UK tax advisers among others to suspend work and freeze the assets of a designated person and to report circumstances when they have ‘reasonable cause to suspect’ any wrongdoing to the Office of Financial Sanctions Implementation. Concerns over sanctions evasion or money laundering should also be reported to the UK Financial Intelligence Unit at the National Crime Agency. Those who act for or receive payments to those on the UK sanctions list face criminal prosecution or a fine unless a licence has been obtained from OFSI to handle the funds. Advisers should warn existing clients to review their investment strategy in Russia file on the new overseas entities register as required and keep apace of alternative visa options...

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